Van Velzen C.S. (hereafter ‘VVCS’, ‘we’, ‘us’ or ‘our’) respects your privacy and processes your Personal Data in accordance with applicable privacy rules and regulations, the GDPR. GDPR stands for General Data Protection Regulation (GDPR; Regulation (EU) 2016/679 of April 27, 2016 and any subsequent revision thereof); in The Netherlands and Belgium, the GDPR is also referred to as AVG.
For the sole purpose of this document ‘Van Velzen C.S.’ comprises Van Velzen C.S. The Netherlands B.V. (‘Van Velzen C.S. (HQ)’), having its registered office in Breda, The Netherlands, Van Velzen C.S. Belgium B.v.b.A., having its registered office in Hoogstraten, Belgium as well as any affiliated entities.
All words in this document, that start with a capital letter, other than at the beginning of a sentence, are definitions as used in the GDPR.
- visitors of our website;
- VVCS' clients (and their employees);
- recipients of VVCS newsletters and other mailings;
- VVCS' prospects;
- people involved in legal proceedings or a transaction in which VVCS acts as service provider;
- suppliers (and their employees);
- network relations (and their employees); and
- third parties that communicate with VVCS.
Personal Data means any information that may identify or may have identified a natural person, as meant in the GDPR.
Which Personal Data does VVCS process?
VVCS processes Personal Data that you have provided to us, Personal Data generated during your (a) visit to our website and (b) reading of our newsletters, and (c) Personal Data we have derived from other sources. Personal Data means any information relating to you, which may include but not be limited to your first, middle and last name, title, contact details like e-mail addresses, mailing and residence address and telephone numbers, your date of birth, nationality and marital status.
Provided by you to VVCS:
- Personal Data you provided at engagement of VVCS or during the course of VVCS providing services to you;
- Contact details and other Personal Data that are necessary for handling your case;
- Personal Data you provided by sending or handing over your (digital) business card;
- Personal Data you provided to VVCS in a conversation, in person, by telephone or through any other medium like social media or an app;
- Personal Data you provided to VVCS in the context of events, seminars, meetings and / or newsletters; and
- Personal Data you provided to VVCS in the context of a job offering, or you applying for a job at VVCS.
Personal Data received via our website:
- Data concerning your visit to our website;
- Data concerning the device you used to visit our website, for example your IP address and the type of device used (desktop, laptop, handheld);
- Your surfing behaviour and interests.
Personal Data received from other sources:
- Personal data received from public online sources such as company websites and social media platforms such as LinkedIn;
- Personal data obtained from the Trade Register of the Chamber of Commerce, the register of the Crossroads Bank for Enterprises, the Land Registry, or any similar register;
- Other Personal Data relating to you that we obtained in handling cases via, amongst others, clients, counterparties, lawyers, accountants, (fiscal) advisers and banks.
Why does VVCS process your Personal Data?
VVCS uses your Personal Data for several purposes on various bases:
- To provide legal and related services performed by VVCS’ associates for and on behalf of VVCS’ clients;
- To comply with our legal obligations, such as data storage obligations and obligations pursuant to the Money Laundering and Terrorist Financing (Prevention) Act, the Law on the prevention of money laundering and terrorist financing and on the restriction of the use of cash, and other similar applicable legislation;
- Based on your explicit, written consent;
- Based on justified reasons, like but not limited to the following purposes:
- To maintain contact and communicate with you;
- To perform marketing activities, such as sending newsletters and other forms of marketing communications, like invitations for events, that may be of interest to you or your organization;
- To process your job application or subscription to one of our events, or any event we participate in;
- To generate statistical information about the use of our website and / or for analysis and improvement of our website. For a detailed explanation of this, see the section on 'Cookies' in this document;
- To secure and improve the security of our website;
- To improve the quality of our services; and
- To conduct client satisfaction surveys.
Protection of your Personal Data
VVCS has taken and continues to take appropriate technical and organizational measures to protect your Personal Data against loss, or against any form of unlawful processing. People at VVCS who have access to your Personal Data or files on VVCS's behalf, have a duty of confidentiality. VVCS applies technological and operational security standards that are generally accepted in its industry, in order to protect Personal Data from being lost, misused, altered or destroyed. If you have any questions about the protection of your Personal Data, or if there are indications of misuse, please contact us: Van Velzen C.S. (HQ), Hans van Velzen, P.O. Box 4976, NL-4803 EZ Breda, The Netherlands, Phone: +31 76 578 1255, E-mail: firstname.lastname@example.org.
Engaging third parties / sharing data with third parties
In certain cases, it may be necessary for VVCS to have third parties process Personal Data. A non-exhaustive overview is provided below:
- Third parties that are relevant to the legal and related services we provide, such as counterparties, lawyers, accountants, (fiscal) advisers, banks, insurers, insurance agents and intermediaries, courts, regulatory authorities and (semi-)government institutions;
- Third parties, such as regulators, enforcement agencies and other organizations, in order for VVCS to comply with statutory obligations; and
Third parties to whom we provide your Personal Data may themselves be responsible towards you for compliance with applicable privacy rules and regulations. VVCS shall neither be responsible nor be liable for the processing of your Personal Data by such third parties. To the extent that a third party processes your Personal Data as a Processor of VVCS and therefore acts at the request, and on the instructions of VVCS, VVCS will conclude a processing agreement with such third party which meets the requirements set out in the GDPR.
Data outside the European Economic Area (‘EEA’)
In order for VVCS to provide its services, it may be necessary for VVCS to transfer Personal Data to a recipient in a country outside the EEA. In such case, VVCS shall ensure that such data transfer is in accordance with the GDPR.
Purposes for the processing of Personal Data
VVCS may process Personal Data for a number of purposes. The data processing may be necessary to perform a contract for the provision of legal services or to comply with a statutory requirement. In some cases we will ask for your explicit consent, for example for the use of certain cookies.
Data may also be processed in connection with a justified interest of VVCS, for example for the purpose of internal administration, effective communication, quality improvement or direct marketing activities, which may be in your interest. In the latter case, an opt-out is always offered.
Your rights as a Data Subject
As a so-called Data Subject, you have certain rights pursuant to the GDPR:
- You have the right to ask VVCS to correct, supplement, delete or block your Personal Data if it is incomplete, incorrect or is being processed in contravention of any statutory provision. If you no longer wish to receive newsletters, emails or invitations to seminars, you can unsubscribe at any time and at no cost via email@example.com.
- You also have the right to request VVCS to inform you of any Personal Data it holds relating to you, or to request transfer of your Personal Data in a structured, commonly accepted and machine-readable form. Additionally, you have the right to transfer these data to a third party.
- You also have the right to object to VVCS’ processing of your Personal Data; you also have the right to withdraw your prior consent to VVCS processing your Personal Data. VVCS will subsequently discontinue the processing of your Personal Data, if such discontinuance is required by law. VVCS however, will continue the processing of your Personal Data if there are justified, imperative grounds to do so, that outweigh your interests, rights and freedom or that are related to bringing, exercising or substantiating a legal act or action.
- At all times, you have the right to file a complaint about VVCS's processing of your Personal Data to the competent Data Protection Authority.
Use of Google Analytics
VVCS uses Google Analytics to obtain insight into e.g. visitor flows, traffic sources and page views on its website. This means that Google acts as Processor in VVCS's processing of your Personal Data. A processing agreement between VVCS and Google applies for this purpose.
Information collected with Google Analytics is anonymized to the extent possible. For example, VVCS does not have detailed insight into individual visitors’ details. Google will never process your full IP address and will always mask part of your IP address.
VVCS appointed Hans A. van Velzen as AVG compliance officer.
In case you require further information or have questions or complaints about VVCS’ processing of your Personal Data, please contact us by:
E-mail: firstname.lastname@example.org; or
By mail: Van Velzen C.S. (HQ), attn. Hans A. van Velzen, P.O. Box 4976, NL-4803 EZ Breda, The Netherlands.
© Van Velzen C.S., v.01, May 2018